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Indian Tribunal Holds that Change in Definition of International Transaction Cannot be Applied Retrospectively for Loan Guarantees

|Approved Changes|India
India

The Mumbai Income Tax Appellate Tribunal recently issued its decision concerning the retrospective application of the definition of the term international transaction for transfer pricing purposes. The case concerned the 2009-10 year of assessment for an Indian taxpayer that had provided guarantees to third party lenders on behalf of its associated enterprises in Germany and Singapore. No fee or commission was charged by the taxpayer to its associated enterprises for the guarantees.

At the …

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